The EU treats GM crops in the same way as GM foods, which face a number of hurdles before they can be marketed.
EU farmers can apply to grow the crops, but they must get permission from the EU regulator. However, each Member State can choose to ignore the authorization and ban the food. Only one GM crop has so far been approved in the EU, but some states have still banned it.
All UK GM crops would have to seek approval from the European Food Standards Agency before they can be sent to Northern Ireland – which imports grain for animal feed, among other things.
Even then, crops could still be banned by Dublin, presenting a new puzzle to ensure affected plants do not cross the invisible Irish border.
The situation is further complicated by the fact that Northern Ireland, like Scotland, has banned genetically modified crops.
At this stage, it is unclear whether Stormont, if EU rules were not taken into account, would follow the UK’s lead. Sinn Fein, Northern Ireland’s largest party, did not respond to requests for comment.
The Northern Ireland Assembly has not been reinstated since the DUP pulled out in February in protest at the protocol, which it accuses of hurting trade with Britain and being undemocratic.
The DUP refused to share power with Sinn Fein after the May 5 election until the protocol was removed or replaced in the UK-EU treaty talks.
There is a debate in Brussels about the merits of genetically modified foods and whether to follow the UK’s example.
Progress towards changing the existing rules is likely to be slow, given opposition from some countries and a ruling by the European Court of Justice that it should be treated as genetically modified.